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located on the old surface facilities area. Based upon detailed measurements taken of these <br />reclaimed areas in the fall of 2013, the 20.2 percent factor for the mine facilities area will be <br />subdivided as follows: The weighting factor for the Vento Portal reclamation area will be 9.42 <br />percent and the weighting factor for the Corley Reclamation area will be 10.78 percent. The <br />contribution from the Refuse Pile, Vento Portal and Corley reclamation areas, will then be <br />summed into the composite final revegetation weighted average value to represent the reclaimed <br />areas at the Southfield Mine area, similar to the approach outlined for the three reference areas <br />described on Permit pages 2.04.10 -4, 2.04.10 -5 and 2.04.10 -5a." <br />16. Page 2.05.4 -27a in the PAP requires more clarification regarding measurement of <br />woody plant densities and delineation of shrub clumps. An acceptable way to clarify which <br />area is defined as a shrub clump versus seeded area would be to reference a specific map <br />(e.g., a map in an Annual Reclamation Report). <br />Response: In connection with the Phase III Final Bond Release Monitoring, performed in <br />September 2013, EFCI's vegetation consultant, met with Ms. Janet Binns and Mr. Rob Zuber in <br />the field to refine concerns over the sampling of shrub densities on all reclaimed areas as well as <br />appropriate delineation of those areas where shrub clumps exist. As a part of that intensive field <br />sampling effort, investigations were made to identify the boundaries of every shrub clump <br />identified in the 2004 Annual Reclamation Report as being planted by the Colorado State Forest <br />Service. The boundaries of every shrub clump were flagged in the field with either plastic pin <br />flags or flagging and these boundaries were then GPSed with a GPS unit. The results from this <br />investigation have been prepared into a single map, showing the location of every Shrub Clump, <br />its number and area, which have been inserted into the 2013 Phase III Revegetation Sampling <br />Report. A copy of this map will be submitted in connection with these responses. <br />17. To be addressed under separate cover at a later date. <br />18. To be addressed under separate cover at a later date. <br />19. On page 2.05.6 -21 of the PAP there is a discussion of potential <br />problems with TDS in runoff, and the text states that EFCI will <br />implement controls if problems are noted. However, there is no process in <br />place to assess this potential problem below Pond 5. The discharge from <br />this pond is not monitored for TDS or conductivity, and there is no <br />monitoring point in the receiving water below this. (Conductivity is <br />monitored in Newlin Creek, Magpie Creek, and Second Alkali Creek, but <br />not below Pond 5.) EFCI needs to address this issue. <br />RESPONSE: <br />Pond 5 discharges into an unnamed tributary of Magpie Creek. This tributary <br />joins Magpie Creek, then the combined flows enter Newlin Creek <br />approximately one mile northeast of the Southfield mine site. <br />At the time Pond 5 was established as a sediment pond by Dorchester Coal <br />Company (Dorchester), a surface mine owned by GEC Minerals (GEC) was <br />operating adjacent to both Magpie Creek and the unnamed tributary. The GEC <br />mining operations were immediately adjacent to Southfield's surface facilities <br />and Pond 5, and runoff from all GEC disturbance areas flowed into the Magpie <br />